Environmental Compliance Hot Topics Hardwood Plywood Veneer Association May 25, 2010

Todays Top 2 SPCC Boiler MACT

Spill Prevention, Control, and Countermeasure (SPCC) Rule

SPCC Rule This impacts me if I have: –An underground storage of greater than 42,000 gallons; or –An aboveground storage of greater than 1,320 gallons (only container of 55 gallons or greater are counted); and –Due to location, could reasonably be expected to discharge oil in quantities that may be harmful into or upon navigable waters of the U.S. –Must exclude consideration of manmade features like dikes, equipment and/or other structures

SPCC Rule Revisions On November 5, 2009, EPA issued revisions to the SPCC Rule The new deadline for compliance with the rule is November 10, 2010 Expect to see increased inspection presence from EPA Typical fines for not having a plan $1000-$7000 If you have a release- escalates to the cost of cleanup, and $$$$ in fines

Action to Take Now Prepare and/or Update your SPCC plan Follow the plan Remember- compliance date is November 10, 2010

Proposed Boiler MACT

What Happened? On April 29, 2010 EPA issued a proposed rule that would reduce toxic air pollutants from boilers and process heaters Provisions in the rule cover- essentially all boilers Currently proposed rule is out for public comment.

Will this Impact Me? If you have a boiler-YES If you plan on installing a boiler –YES

Best Scenario You do not have a boiler Your existing boiler is Natural gas fired only (exempt) Your existing boiler is small in size (<10 MMBTU/HR) You have a temporary boiler only (operates less than 180 consecutive days)(exempt)

Whats Required for the Best Scenario Biennial Tune-up –Inspect the burner-clean or replace components as necessary –Inspect the flame pattern-make adjustments to optimize –Inspect the system controlling the air-to-fuel ratio, and ensure calibrated and functioning properly –Minimize the CO emissions following manufacturer specifications –Measure CO emissions before and after adjustments Annual Report

Most Stringent Scenario You are a HAPS major source –Emit 10 tons or more of an individual HAP –Emit 25 tons or more of combined HAPs Focus on reductions for carbon monoxide, particulate, HCl, Mercury, and dioxin/furans. Standards are based on the fuel type for all parameters and both fuel type and boiler design for dioxin/furans and carbon monoxide standards.

Whats Required for the Most Stringent Scenario? Installation of Continuous Monitors Installation of Controls Energy Assessment Initial and Annual Source Testing ($20-$30K)

Most Common Scenario You are not a HAPS Major but an AREA SOURCE –Emit less than 10 tons per year of any individual HAP –Emit less than 25 tons per year of any combination of HAPs Boilers are greater than 10 MMBTU/HR* *(Were not looking at coal for this scenario)

Whats Required for the Most Common Scenario? Initial and Annual Source Testing for Carbon Monoxide ($2500-$3000) New limits for particulate and CO for new sources of oil and biomass Particulate, CO, and mercury for coal sources New limits for Carbon Monoxide for existing sources –Will require Generally Achievable Control Technology (GACT). –Methods, practices and techniques are commercially available and appropriate Energy Assessment

Energy Assessment Requirements Energy assessment must be performed by qualified personnel A qualified specialist is someone: – Who has successfully completed the Department of Energys Qualified Specialist Program for all systems or – A professional engineer certified as a Certified Energy Manager by the Association of Energy Engineers.

Energy Assessment Requirements Complete a visual inspection and review of the boiler system. Establish operating parameters of the facility energy systems Identify the high energy sources, conservation measures, and potential savings Prepare a comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the timeline

Other Changes Proposed for the Boilers Proposed standards vary based on the fuel type EPA is proposing either daily or monthly standards Sources w/o wet scrubbers that have particulate and mercury emission limits will require continuous opacity monitors Sources electing fuel sampling to comply with the mercury standard are required to sample monthly Recordkeeping and compliance reporting requirements

Compliance Timeline The final rule is to be complete by December 16, Compliance is required three years following the date of publication of the final rule.

Ways to send comments… Fax: Mail: EPA Docket Center Environmental Protection Agency Mailcode: 2822T 1200 Pensylvania Av., NW Washington, DC DOCKET- ID No. EPA-HQ-OAR

Separate but Related Action EPA has proposed updated definitions of nonhazardous wastes and fuels with respect to boilers dictating how a unit is regulated under the boiler MACT Majority of the fuels we use are clean biomass. If the fuels are under the control of the generator and not contaminated will be considered non- hazardous solid waste. Concerns-with the treated wood, painted wood, construction debris with contaminants, and materials generated somewhere else.

Heather Bartlett Principal Engineer SLR International Corp Address: 1800 Blankenship Road, Suite 440, West Linn, OR Office: (503) Facsimile: (503) Website: